HomeMy Public PortalAboutPRR 14-1275RECEIVED 08/0B/2014 13:08 5613946102 SBV
OB10812014 1328 Commerce Group FAX)95436=7
RECORDS REQUEST (the "Requeat'l
Date of Request 8(8(2014
Requestor's Request ID#: 124
REQUESTEE: Custodian of Records - Sweetapple, Brooker, Varkas, P.L
REQUESTOR: CG Acquisition Company, Inc.
REQUESTOR'S CONTACT INFORMATION: E -Mail; records@commeroe- group.com
Fax; 954- 360.0807; Address: 1280 West Newport Center Drive, Deerfield Beach, FL 33442
REQUEST:
Please provide all Public Records which confirm Attorney Sweetapple's
statement In the second sentence of numbered paragraph 14 of the
n an s o on or an ons stns am art n oy e, aunsel
Of RSGGFd, onaihan O {sic}Artd Wi1Ga:n R11167—
Esquire, which was filed by Attornoy Sweetapple
ADDITIONAL INFORMATION REGARDING REQUEST:
THIS REQUEST IS MADE PURSUANT TO PUBLIC RECORDS ACT,
CHAPTER 119 OF THE FLORIDA STATUTES AND IS ALSO REQUESTED UNDER THE
COMMON LAW RIGHT TO KNOW, THE COMMON LAW RIGHT OF ACCESS; AND
ANY STATUTORY RIGHT TO KNOW (INCLUDING, WITHOUT LIMITATION, ANY
STATUTORY RIGHT OF ACCESS, AS APPLICABLE). THIS REQUEST IS ALSO MADE
PURSUANT TO THE RIGHTS OF THE REQUESTOR PROVIDED IN THE FLORIDA
CONSTITUTION,
IT IS REQUESTED THAT THIS RECORDS REQUEST BE Fin FILLED IN ELECTRON, IQ
FORM. IF NOT AVAILABLE IN ELECTRONIC FORM, MAIN REQUESTED THAT THIS
RECORDS REQUEST BE FULFILLED ON I1 X 17 PAPER NOTE IN ALL CASES (UNLESS
IMPOSSDILE) THE COPIES SHOULD BE TWO SIDED AND HOULD BE BILLED IN
ACCORDANCE WITH Section 119.070) (a) (2)
ALL ELECTRONIC COPIES ARE REOLE TED TO BE SENT BY E:NAIL DELIVERY
PLEASE PROVIDE THE APPROXIMATE COSTS (IF ANY) TO FULFILL THIS PUBLIC
RECORDS REQUEST IN ADVANCE.
It will be required that the Requestor approve of any costa, asserted by the Agency (as defined In
Florida Statute, Chapter 119.01 (Definitions)), in advance of any costa imposed to the Requestor by
the Agency.
I:P/NPR/FRR
04.22.13 FORM
1275
P.0021004
RECEIVED 08/08/2014 13:08 5613946102 SBV
0810812014 13:29 Commerce Group M09543600807 P.0031004
Martin R O'Boyle V. Town orouitlmem
CASE M. 302014CA004474XXKXI2AO (PALM BEACH COUNM
10. Following the meeting, John Randolph wrote a letter to William Ring informing him that the
meeting did not involve settlement discussions and therefore it would not be treated as confidential,
Exhibit "111.
11. After the meeting, O'Boyle commenced to have airborne banners flown on a daily basis over
Palm Beach County. Some of the banners read:
12. On June 6, 2014, O'Boyle had his attorney and business associate, William Ring, Esquire,
form a Florida limited liability company called "Sweet Apple Sober Houses, LLC ", Exhibit "2 ", an
obvious reficrence to a defense counsel's surname.
13. In addition, on June 13, 2014, O'Boyle appeared before a meeting of the Gulf Stream Town
Commission and made false and defamatory allegations against Gulf Stream's co- counsel, Robert
Sweetapple, stating that a Judge of the First District Court of Appeal had found that uAfr, Sweetapple
consistently misrepresented testimony and failed to acknowledge well - established ease law,
including Supreme Court precedents." (Exhibit 1130) This statement is patently untrue and was made
to undermine the Town's confidence in its attorney,
14. The above threats and conduct have occurred with the knowledge, cooperation and complicity
of William Ring, Jonathan O'Boyle and the O'Boyle Law Firm, Specifically, this udseonduct is being
4
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20 S.E. 3" ftw, 130CARAM4 FL=oA334323911
RECEIVED 08/08/2014 13:08 5613946102 SBV
08/0812014 1329 Commerce Group ffAMS43B00801
Martin E. O'Boyle v, Town of GUIMream
undertaken to pressure and intimidate defense counsel into not pursuing the issue of whether the
O'Boyle Law Firm is a bona fide Interstate Law pirm,
15. The issue of whether the O'Boyle Law Finn is a bona fide Interstate Law Firm is one that
should be resolved according to hew. It should not be the subject of harassment, intimidation and air
raids by opposing counsel and their client.
16, The misconduct is unprofessional, unethical and it constitutes an egregious example of
litigation abuse, These tactics go beyond zealous representation and are designed to interfere with
defame counsels' ethical obligation to their client. Such conduct undermines society's commitment
to the resolution of disputes in courts of law, rather than in the stoats or in the sky,
17. While citizens enjoy the constitutional right of free speech, that Protection is afforded to
truthful speech, and while attorneys must zealously represent their client's interests, they are also
officers of the court, and are Prohibited from disparaging witnesses and attorneys, or otherwise
undermining the admirdstration of justice
IS. It is well settled that the trial court has inherent jurisdiction to sanction patties and their
counsel fur litigation abuse, in this instance, plaintiff and his counsel have sought to cease any
litigation or determination of the bona fides of the O'Boyle Law Finn by threatening and instituting
reprisals against counsel, their client and families,
19. While O'Boyle has the right to continue to make it spectacle of himself he, with the assistance
Of counsel, cannot impugn, malign and attempt to extort opposing Parties or their counsal as part of
the litigation process.
20. Abusive conduct is not a novelty for 0' Boyle, who has left a historic trail.ofabusivelitigation.
5
LAN OFFICES Or"S AFFta, BROMa &vAi Uk P.L.
205.3.3'0 Starr, nocARArot{ Fi.oamA33432 -3911
P.0041004
TOWN OF GULF STREAM
PALM BEACH COUNTY, FLORIDA
Delivered via e-mail
November 4, 2014
CG Acquisition Company, Inc. [mail to: records @commerce - group.com]
Re: GS #1275 (124)
Please provide all Public Records which confirm Attorney Sweetapple's statement in the second
sentence of numbered paragraph 14 of the Defendant's Motion For Sanctions Against Plaintiff,
Martin E. O'Boyle, Counsel of Record, The O'Boyle Law Firm, P. C., Jonathan O' [sic] And
William Ring, Esquire, which was filed by Attorney Sweetapple.
Dear CG Acquisition Company, Inc. [mail to: recordsaa,commerce- groun.coml,
This letter is in response to the public records you have requested which we received August 8,
2014. Your original requests can be found at the following link htti)://www2.galf-
stream .org /WebLink8 /0 /doc /20068/Paeel .asnx.
Be advised that no such records exist.
We consider this matter closed.
Sincerely,
Town Clerk
Custodian of the Records